Erkenning en omzetting van buitenlandse adopties in Nederland: Over de betekenis van beide fenomenen in het Nederlandse internationaal privaatrecht

The dissertation concerns the question what the recognition and conversion of a foreign adoption mean under Dutch private international law. It examines this issue from both a doctrinal perspective and by considering current regulations and potential future regulations. These regulations include the Hague Adoption Convention of 1993, the Dutch-Belgian Recognition and Enforcement Convention of 1925, the Dutch-Italian Recognition and Enforcement Convention of 1959, Title 6 of Book 10 of the Dutch Civil Code, the unwritten Dutch international adoption law, the prospective treaty on legal parenthood by the Hague Conference on Private International Law, and the potential future Parenthood Regulation of the European Union.
From a doctrinal legal perspective, the main conclusion is that the recognition of a foreign adoption in the Netherlands essentially means that all of the lineage effects that have arisen in the foreign country of origin must be adopted by the Netherlands. Furthermore, it is concluded that the conversion of a foreign adoption implies any changes in these effects.
Regarding existing legislation, the primary finding is that the rules concerning the legal effects of recognizing a foreign adoption largely align with theoretical principles. However, concerning the potential future regulations, it is concluded that adoptions have thus far been erroneously regarded as regular parenthood relationships.